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ARTICLE · 15 SEPTEMBER 2026

When A Chatbot Becomes A Search Engine: Lessons From The Commission’s Latest DSA Designations

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The European Commission has designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act, marking the first time a generative AI assistant has been classified this way. This designation, alongside Reddit and Roblox being named as Very Large Online Platforms, introduces systemic risk assessment obligations, independent audits, and advertising transparency requirements that most AI products have not previously faced. What does this mean for other AI assistants with web-search capabil

BelgiumTechnology
Olivia Ward
Olivia Ward

ChatGPT is now a search engine. At least, that's how Brussels sees it.

On 31 August, the European Commission designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act (the DSA), and named Reddit and Roblox as Very Large Online Platforms (VLOPs). All three had self-reported crossing the 45 million average monthly EU user threshold that triggers the DSA's top supervisory tier; ChatGPT by some distance (OpenAI reported around 159 million monthly users for its search function), Reddit at 57.2 million, and Roblox scraping over the line at roughly 46.6 million.

The Reddit and Roblox designations follow familiar logic: both enable users to disseminate third-party content to the public at scale, squarely engaging the DSA's VLOP category. The significant development is ChatGPT.

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